Tax/Estate Planning & More

Part Three of the TCJA Attribution Rules: Down the Rabbit Hole

Posted in Tax/Estate Planning & More | Posted on Sep 5, 2019

In our blog post titled “Owning” Shares that aren’t Yours: The Code’s Confusing Definition of “Ownership”, we introduced how U.S. Shareholders of a...Read more

Part Two of the TCJA Attribution Rules: The Expansion Upward

Posted in Tax/Estate Planning & More | Posted on Sep 5, 2019

In our blog post titled “Owning” Shares that Aren’t Yours: The Code’s Confusing Definition of “Ownership”, we introduced how U.S. Shareholders may be...Read more

Family Attribution Rules

Posted in Quick Guides, Tax/Estate Planning & More | Posted on May 11, 2022

What is Attribution? Attribution is an artificial concept used for tax purposes to prevent tax avoidance. This artificial concept treats a person/taxpayer as...Read more

“Owning” Shares that aren’t Yours: The Code’s Confusing Definition of “Ownership”

Posted in Tax/Estate Planning & More | Posted on Aug 28, 2019

The Code employs various definitions of what constitutes “ownership” in various circumstances, and with regards to the classification of foreign companies as CFCs,...Read more

Is a Nonresident Alien’s Sale of a Partnership Interest a U.S. Trade or Business?

Posted in Tax/Estate Planning & More | Posted on Aug 23, 2019

Our previous post, The Code Fails to Define a “U.S. Trade or Business,” even though You’re Still on the Hook for Paying Taxes...Read more

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